In the case of National Labor Relations Board v. Mattison Machine Works (1960), the Supreme Court ruled in favor of the National Labor Relations Board (NLRB). The dispute arose when Mattison Machine Works refused to bargain with a union that had been certified by NLRB as an exclusive representative for its employees, arguing that some votes were cast by ineligible voters and thus, should have been excluded from certification. However, NLRB rejected this argument stating it was not raised during representation proceedings and therefore could not be used as grounds for refusal to bargain. The Supreme Court upheld NLRB's decision emphasizing that employers must raise any objections they may have about voter eligibility or other issues related to representation elections during those proceedings themselves rather than using them later on as reasons for refusing to negotiate with a duly certified union.

In the dissenting opinion for the National Labor Relations Board v. Mattison Machine Works case, Justice Frankfurter argued that the majority's decision was a departure from established principles of labor law and administrative law. He contended that an employer should not be held liable for unfair labor practices unless it is proven beyond reasonable doubt that they had knowledge of their employees' union activities before taking adverse action against them. According to him, this requirement is necessary to maintain fairness in industrial relations and protect employers from unfounded accusations. Furthermore, he criticized the majority's reliance on circumstantial evidence to infer anti-union animus on part of the employer without direct proof or admission by management officials involved in making employment decisions.